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Full text of "Explanation of Significant Differences for Areas of Contamination CS-16/CS-17, SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5"

Massachusetts Military Reservation 




Explanation of Significant Differences for 
Areas of Contamination CS-16/CS-17, SD-3/ 
FTA-3/CY-4, SD-4, and SD-5/FS-5 

Final 
August 2013 



Prepared for: 
AFCEC/MMR 
Installation Restoration Program 
322 East Inner Road 
Otis ANGB, MA 02542 

Prepared by: 
Portage, Inc. 
1075 S. Utah Ave., Suite 200 
Idaho Falls, ID 83402 



TABLE OF CONTENTS 

ACRONYMS AND ABBREVIATIONS iv 

1.0 INTRODUCTION 1-1 

1 . 1 Statement of Purpose 1-2 

1 .2 Authorizing Signatures 1-3 

2.0 SITE HISTORY, CONTAMINATION, AND SELECTED REMEDY 2-1 

2.1 Site Location and Description 2-1 

2.2 Land Use and Site History 2-2 

2.2.1 CS-16/CS-17 2-4 

2.2.2 SD-3/FTA-3/CY-4 2-7 

2.2.3 SD-4 2-10 

2.2.4 SD-5/FS-5 2-13 

2.3 Selected Remedy 2-16 

2.3.1 ROD CS-16/CS-17 Source Areas, Final, May 1999 2-16 

2.3.2 ROD AOC FTA-2/LF-2, PFSA/FS-10/FS-1 1, SD-2/FS-8, SD-3/FTA-3/CY-4, 
SD-4, and SD-5/FS-5 Source Areas, Final, September 1998 2-17 

2.3.2.1 AOC SD-3/FTA-3/CY-4 2-17 

2.3.2.2 AOC SD-4 2-17 

2.3.2.3 AOCSD-5/FS-5 2-17 

2.3.3 Final 2000 ESD, October 2000 2-18 

2.3.4 Final 2003 ESD, January 2003 2-18 

3.0 BASIS FOR THE EXPLANATION OF SIGNIFICANT DIFFERENCES 3-1 

3 . 1 Establishment of New Surface Soil Remedial Action Levels 3-1 

3.2 Removal of the Asphalt-Batching Component from the Selected Remedy of AOC SD- 
5/FS-5 3-7 

3.3 Implementation of an SVE System to Treat TCE and PCE in Subsurface Soil at AOC SD-5 
Detail A 3-8 



i 



3.4 Expansion of Offsite Disposal Options for Excavated Soil from AOC SD-5/FS-5 to Include 
RCRA Subtitle D Facilities 3-8 

3.5 Expansion of Offsite Disposal Options for Excavated Soil from AOC SD-5/FS-5 to Include 
RCRA Subtitle D Facilities 3-9 

4.0 DESCRIPTION OF SIGNIFICANT DIFFERENCES 4-1 

4. 1 Establishment of New Surface Soil Remedial Action Levels 4-1 

4.2 Removal of the Potential Sediment Excavation Reqiurement from the Selected Remedy at 
SD-4 4-4 

4.3 Removal of the Asphalt-Batching Component from the Selected Remedy of AOC SD- 
5/FS-5 4-4 

4.4 Implementation of an SVE System to Treat TCE and PCE in Subsurface Soil at AOC SD-5 
Detail A 4-4 

4.5 Expansion of Offsite Disposal Options for Excavated Soil from AOC SD-5/FS-5 to Include 
RCRA Subtitle D Facilities 4-5 

5.0 STATUTORY DETERMINATION 5-1 

6.0 REFERENCES 6-1 

Figures 

Figure 2-1 MMR Location Map 2-3 

Figure 2-2 CS-16/CS-17 Overview 2-6 

Figure 2-3 SD-3/FTA-3/CY-4 Overview 2-8 

Figure 2-4 SD-4 Overview 2-12 

Figure 2-5 SD-5/FS-5 Overview 2-15 

Tables 

Table 2-1 Summary of changes in cleanup levels and basis for selection in the 2003 ESD 2-21 

Table 2-2 MCP S-l/GW-1 standards for petroleum hydrocarbons selected in the 2003 ESD 2-22 

Table 3-1 Selection process for new surface soil RALs for organic contaminants 3-5 

Table 3-2 Additional and revised RALs (0-2 ft bgs) 3-5 



ii 



Table 4-1 Comparison of original (ROD RALs) and revised or new RALs for AOCs CS-16/CS-17, 

SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5 affected by this ESD 4-1 

Appendix 

Appendix A MassDEP Concurrence Letter 



iii 



ACRONYMS AND ABBREVIATIONS 

ABB-ES ABB Environmental Services, Inc. 

AFCEC Air Force Civil Engineering Center 

AFCEE Air Force Center for Environmental Excellence (pre- June 2007)/Air Force Center 
for Engineering and the Environment (post- June 2007) 

ANG Air National Guard 

AOC area of contamination 

ASG Automated Sciences Group 

AVGAS aviation gas 

bgs below ground surface 

BSVR biosparging and soil vapor recovery 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CFR Code of Federal Regulations 

CMR Code of Massachusetts Regulations 

COC contaminant of concern 

CS chemical spill 

CSA Central Storage Area 

CY coal yard 

DDT dichlorodiphenyltrichloroethane 

DSR data summary report 

DSRP Drainage Structure Removal Program 

ECC Environmental Chemical Corporation 

EPA U.S. Environmental Protection Agency 

EPH extractable petroleum hydrocarbons 

ERA ecological risk assessment 

ESD explanation of significant differences 



IV 



FS fuel spill 

FTA Fire Training Area 

GPS Global Positioning System 

HAZWRAP Hazardous Waste Remedial Action Program 

HEC hazard equivalent concentration 

HI hazard index 

HLA Harding Lawson Associates 

IRP Installation Restoration Program 

LF landfill 

LTM long-term monitoring 

LUC land use control 

MADEP Massachusetts Department of Environmental Protection 

MCP Massachusetts Contingency Plan 

mgd million gallons per day 

MMR Massachusetts Military Reservation 

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NDIL Nondestructive Inspection Laboratory 

NGB National Guard Bureau 

OU operable unit 

OWS oil/water separator 

PAH polycyclic aromatic hydrocarbon 

PCB polychlorinated biphenyl 

PCE tetrachloroethene 

PFSA Petroleum Fuel Storage Area 

ppb parts per billion 



PRA 


preliminary risk assessment 


QC 


quality control 


RAH 


Risk Assessment Handbook 


RAL 


remedial action level 


RAO 


remedial action objective 


RCRA 


Resource Conservation and Recovery Act 


RI 


remedial investigation 


ROD 


record of decision 


RSL 


regional screening level 


SARAP 


Source Area Remedial Action Program 


SD 


storm drain 


SERA 


screening-level ecological risk assessment 


SI 


site investigation 


STCL 


soil target cleanup level 


STP 


sewage treatment plant 


SVE 


soil vapor extraction 


SVOC 


semivolatile organic compound 


TCE 


trichloroethylene 


TCL 


target compound list 


TCLP 


Toxicity Characteristic Leaching Procedure 


TMB 


trimethylbenzene 


TN&A 


TN and Associates 


TPH 


total petroleum hydrocarbons 


USAF 


U.S. Air Force 


use 


United States Code 



USCG U.S. Coast Guard 

UST underground storage tank 

UU/UE unlimited use/unrestricted exposure 

UVF ultraviolet fluorescent 

VOC volatile organic compound 

VPH volatile petroleum hydrocarbons 



vii 



1.0 INTRODUCTION 

This explanation of significant differences (ESD) has been prepared to document changes to the 
selected remedy for areas of contamination (AOCs) in the Source Area Remedial Action 
Program (SARAP). The AOCs addressed under this ESD are part of the Otis Air National Guard 
(ANG) Installation Restoration Program (IRP) at the Massachusetts Military Reservation 
(MMR). These AOCs consist of the following: 

• Chemical Spill No. 1 6 (CS- 1 6)/Chemical Spill No. 1 7 (CS- 1 7) 

• Storm Drain No. 3 (SD-3)/Fire Training Area-3 (FTA-3)/Coal Yard No. 4 (CY-4) 

• Storm Drain No. 4 (SD-4) 

• Storm Drain No. 5 (SD-5)/Fuel Spill No. 5 (FS-5) 
This ESD modifies the following decision documents: 

• Record of Decision, Area of Contamination CS-16/CS-17 Source Areas, Final, May 1999 
(Air Force Center for Environmental Excellence [AFCEE] 1999). 

• Record of Decision, Areas of Contamination FTA-2/LF-2, PFSA/FS-10/FS-ll, SD-2/FS-6/ 
FS-8; SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5 Source Areas, Final, September 1998 
(AFCEE 1998). 

• Explanation of Significant Differences to the Final Record of Decision, Areas of 
Contamination FTA-2/LF-2, PFSA/FS-10/FS-22, SD-2/FS-6/FS-8, SD-3/FTA-3/CY-4, SD- 
4, and SD-5/FS-5 Source Areas, Final, October 2000 (AFCEE 2000a). 

• Explanation of Significant Differences Areas of Contamination, CS-10 (A, B & E), CS- 
16/CS-17, FS-9, SD-2/FS-6/FS-8, and SD-3/FTA-3/CY-4, Final, January 2003 (AFCEE 
2003 a). 

Specific changes to the selected remedies presented in the decision documents listed above 
include the following: 



1-1 



• Establishment of new surface soil remedial action levels (RALs) for several contaminants 
of concern (COCs) and for contaminants not considered COCs in the RODs 

• Removal of the asphalt-batching component from the selected remedy for AOC SD-5/FS-5 

• Implementation of a soil vapor extraction (SVE) system to treat trichloroethylene (TCE) 
and tetrachloroethene (PCE) in subsurface soil at SD-5 Detail A 

• Expansion of offsite disposal options for excavated soil from AOC SD-5/FS-5 to include 
Resource Conservation and Recovery Act (RCRA) Subtitle D facilities (42 United States 
Code [USC] § 6901 et seq.) 

The MMR is a National Priorities List site under CERCLA. The Comprehensive Environmental 
Response, Compensation, and Liability Identification System (CERCLIS) number for the site is 
MA2570024487. 

1.1 Statement of Purpose 

This ESD was developed in accordance with § 117(c) of CERCLA and 40 Code of Federal 
Regulations (CFR) § 300.435(c)(2)(l) of the National Oil and Hazardous Substances Pollution 
Contingency Plan (NCP), which require the publication of an ESD to describe the significant 
difference(s) between the selected remedial action and the modified remedial action, including 
an explanation of why such changes were made. The format of the ESD is in accordance with the 
U.S. Environmental Protection Agency's (EPA's) A Guide to Preparing Superfund Proposed 
Plans, Records of Decision, and Other Remedy Selection Decision Documents (EPA 1999). 

The Director of the AFCEC, U.S. Air Force, and the Director of the Office of Site Remediation 
and Restoration, EPA New England Region, have been delegated the authority to approve this 
ESD. The ESD will become part of the Administrative Record for the six AOCs addressed, in 
accordance with the NCP [40 CFR § 300.825(a)(2)]. The Administrative Record is available for 
public review at the AFCEC IRP Office (322 East Inner Road, Otis ANG Base, Massachusetts, 
02542) Monday-Friday, 8 a.m.-4 p.m., excluding federal and state holidays. 



1-2 



1.2 Authorizing Signatures 



The following signatures represent the decision to authorize this ESD. 



Air Force Civil Engineer Center 




Director 



Date 



U.S. Environmental Protection Agency 




James T. Owens, III 
Director ^ 
Office of Site and Restoration 



Date 



1-3 



2.0 SITE HISTORY, CONTAMINATION, AND SELECTED REMEDY 



This section presents background information on the CS-16/CS-17, SD-3/FTA-3/CY-4, SD-4, 
and SD-5/FS-5 source areas, including an overview of the physical and chemical characteristics, 
history, and selected remedies for these source areas. 

2.1 Site Location and Description 

The MMR is located on western Cape Cod in Barnstable County, Massachusetts, approximately 
60 miles south of Boston and immediately southeast of the Cape Cod Canal (see Figure 2-1). 
MMR occupies approximately 22,000 acres within the towns of Bourne, Falmouth, Mashpee, 
and Sandwich. The MMR is organized into the following four principal functional areas: 

• Range Maneuver and Impact Area. This 14,000-acre area occupies the northern 70% of 
MMR and is used for training and maneuvers. 

• Cantonment Area. Occupying 5,000 acres in the southern portion of MMR, this area is the 
location of administrative, operational, maintenance, housing, and support facilities for the 
base. This is the most actively used section of the MMR. Otis ANG Base, Camp Edwards, 
and Air Station Cape Cod all operate facilities, including the flightline area operated by 
Air Station Cape Cod (U.S. Coast Guard), which are located in the southeast portion of the 
Cantonment Area. 

• Massachusetts National Cemetery. This area consists of 750 acres along the western edge 
of the MMR and contains the Department of Veterans Affairs cemetery and support 
facilities. 

• Cape Cod Air Force Station. This area occupies 101 acres of the northern portion of the 
Range Maneuver and Impact Area and consists of a fixed-base, phased-array warning 
system known as PAVE PAWS. 



2-1 



2.2 Land Use and Site History 



Although military activity began at MMR as early as 1911, most operations have occurred since 
1935 and have consisted of two general types: (1) mechanized Army training and maneuvers and 
(2) military aircraft operations, maintenance, and support. 

Intensive Army activity occurred with the onset of World War II and continued through 
demobilization following the war (1940 to 1946). Major aircraft operations associated with 
surveillance and air defense occurred from 1955 to 1970. Although aircraft operations continue 
today, the greatest potential for release of contaminants to the environment was between 1940 
and 1970. Tenants at MMR include, or have included, the U.S. Coast Guard (USCG) (Air Station 
Cape Cod), Army National Guard (Camp Edwards), U.S. Air Force (USAF) (Cape Cod Air 
Force Station), ANG (Otis Air National Guard Base), Veterans Affairs National Cemetery, U.S. 
Marine Corps, U.S. Department of Agriculture, and the Commonwealth of Massachusetts. 

Activities at MMR that have the potential for contaminating the environment have included the 
storage, handling, and disposal of solvents and petroleum fuels as well as the leakage of these 
materials into stormwater drainage systems and the sanitary sewer system. Landfill operations, 
firefighter training, coal and ash storage, and numerous chemical and fuel spills have also 
resulted in environmental contamination. 



2-2 



FIGURE 2-1 MMR LOCATION MAP. 




■ Plum* Boundary (0»n*d w«*t intmd) 

Town Bmroary 

IRP Sowtm Area 



4 



I.JM 



-j.- ■- : = : - i r~rr wnim n 



FIGURE 2-1 

EXPLANATION OF SIGNIFICANT DIFFERENCES 
FOR APEAS OF CONTAMINATION C £ -1&'C S-1 7 , 
SD-J/FTA-3.'CY-4. SO -4, AND SD-S/FS-S SITE 
LOCATIONS 



CH2MHILL 



2-3 



The following subsections provide background information, including land use and site histories, 
on the sites encompassed by this ESD. 

2.2.1 CS-16/CS-17 

AOC CS-16/CS-17 occupies approximately 80 acres along the southern boundary of the 
Cantonment Area near the Falmouth Gate and is located within the town of Sandwich, near the 
intersection of the Falmouth-Mashpee town lines (Figure 2-1). The source areas at AOC CS- 
16/CS-17 addressed in this ESD are the active and inactive sludge drying beds and the former 
sewage sludge disposal area. The locations of these sites are illustrated in Figure 2-2. Significant 
historical events include the following: 

• 1936: A 0.9-million-gal-per-day (mgd) primary wastewater treatment facility was 
constructed at the current location of AOC CS-16/CS-17 to serve the MMR. 

• 1941 : A 3-mgd secondary wastewater treatment facility replaced the primary facility at the 
same location. Major treatment system components included two Imhoff tanks, two high- 
rate trickling filters, two secondary clarifiers, 24 sand filter beds, and 22 sludge drying 
beds. Waste battery electrolyte, cleaners, solvents, and paint thinners from various MMR 
operations were reportedly discharged to this sanitary sewer, and it is assumed that metals 
and organic chemicals contained in these waste materials partitioned to organic matter 
concentrated in the treatment sludge. Although some chemicals may have volatilized to the 
atmosphere during the treatment process, others may have passed through the former 
sewer treatment plant (STP) and discharged to the final effluent. 

• Before 1960s: Reportedly, tank-bottom sludge from JP-4 jet fuel, heating oil, and aviation 
gasoline (AVGAS) tanks was placed in the sludge drying beds. 

• 1995: The ANG upgraded the former STP to discharge effluent to new sand filter beds 
near the Cape Cod Canal. A 14-mile pipeline, a pumping station, and associated basins at 
the former STP and sand filter beds near the Cape Cod Canal were constructed. Discharge 
to the onsite active sand filter beds has been discontinued. The upgraded former STP 
began operation in 1995. 



2-4 



1996: Sludge remaining in the Imhoff tanks was removed and treated before demolition. 

1997: Demolition of the former STP concrete structures was completed. 

The following investigations and remedial actions were conducted at AOC CS-16/CS-17: 

1983-1985: The U.S. Geological Survey conducted a groundwater survey identifying the 
existence of a groundwater plume in Ashumet Valley. 

1987: The former STP and off-reservation groundwater study included multimedia 
sampling to evaluate former STP activities possibly related to the Ashumet Valley 
groundwater plume. 

1987-1989: A site investigation (SI) that included soil and groundwater sampling was 
conducted. 

1994: A remedial investigation (PJ) was conducted; soil and groundwater sampling, nature 
and extent characterization, fate and transport of contamination, and risk assessment were 
included. 

1998: A feasibility study was completed to evaluate remedial alternatives to mitigate risk 
resulting from concentrations of contaminants in soil. 



DETAIL C 




BASE BOUNDARY 



REV 



REVISIONS 



RELEASED FOR FINAL CLOSURE REPORT 



DATE 



09-10-02 



APPROVED 



B.B.T. 




MMR OVERVIEW 



1 



SCALE IN MILES 



ENVIRONMENTAL CHEMICAL CORPORATION 
5 KITTRIDGE ROAD 
OTIS ANGB. MA 02542 



FIGURE 1-2 
CS-16/CS-17 
SITE OVERVIEW MAP 



MASSACHUSETTS MILITARY RESERVATION 



MULTIPLE SOURCE AREA REMEDIATION 



PROJECT CODE; 

5422.019 



B 



CONTRACT CODE: 

F41624-97-D-8009 



DRAWN BY; 

E.H. SAHAGIAN 



AS SHOWN 



n/r= 

10-02-00 



SHEET NO.; 

1 OF 1 



REVISION 

A 



FIGURE 2-2 CS-16/CS-17 OVERVIEW. 



2-6 



• 2000-2001: Surface and subsurface soil delineation sampling was conducted to determine 
the boundaries of soil excavation based on remedial action levels (RALs). 

• 2001-2002: Excavation, confirmation sampling, and site restoration activities were 
conducted at AOC CS-16/CS-17. 

2.2.2 SD-3/FTA-3/CY-4 

AOC SD-3/FTA-3/CY-4 is located near the southeastern border of the MMR in a moderately 
industrialized area on the eastern side of the runways, covering approximately 30 acres (Figure 
2-1). The source areas of AOC SD-3/FTA-3/CY-4 addressed in this ESD are illustrated in Figure 
2-3. The majority of the AOC is bordered by Granville Avenue on the west and the ANG 
Ammunition Storage Area on the east. A small portion of SD-3 is located east of the ammunition 
storage area. The SD-3 stormwater drainage ditch receives runoff from this area and the eastern 
edge of the aircraft maintenance ramp, the former Central Heating Plant, and associated 
stockpiles of coal and surficial coal ash. FTA-3 was located in an area where construction debris 
and coal ash were disposed of after construction of the Central Heating Plant in 1955. 



2-7 




LEGEND 





DESCRIPTION 




REMEDIATION SITE 





POWER POLE 




FENCE LINE 


188 


BUILDING NUMBERS 


"trf.3 


CONTOUR LINE 




VEGETATION 




AIR FORCE CENTER FOR 
ENVIRONMENTAL EXCELLENCE 
322 EAST INNER ROAD 
OTIS ANGB, MA 02542 



FIGURE 1-2 
SD-3/FTA-3/CY-4 
SITE MAP 



MASSACHUSETTS MILITARY RESERVATION 



SD-3/FTA-3/CY-4 REMEDIAL ACTION REPORT 



PROJECT CODE: 



B 



CONTRACT CODE: 



DRAWN BY: 

J.M. ALVES 



AS SHOWN 



DATE: 

6-17-04 



SHEET NO.: 

1 OF 1 



REVISION 
1 



FIGURE 2-3 SD-3/FTA-3/CY-4 OVERVIEW. 



2-8 



AOC SD-3/FTA-3/CY-4 is located within the fenced flightline security area. Access to areas 
within the flightline area is controlled with fences and guard posts, and activities not related to 
aircraft operations are limited and strictly controlled. Fences around the flightline areas are 
inspected daily by base security. These site access restrictions are expected to remain in place 
through the duration of the current lease (expiration date of 2026) and the planned 25-year 
renewal. Significant historical events include the following: 

• 1950s: The SD-3 drainage ditch was constructed to receive the discharge from storm 
drains serving aircraft hangars and several streets west of Granville Avenue and the 
discharge from the Central Heating Plant. 

• 1955-1978: Coal was stockpiled directly on the ground prior to installation of a concrete 
storage pad. 

• 1955-1992: The coal ash disposal area received coal ash and fly ash from the Central 
Heating Plant. 

• 1956-1958: FTA-3 was used for firefighter-training exercises. Subsequent to firefighter- 
training activities, the site was backfilled with construction debris, fill, and coal ash. 

The following investigations and remedial actions were conducted at AOC SD-3/FTA-3/CY-4: 

• 1987: An SI was performed to assess the presence of contamination in surface water, 
sediment, soil, and groundwater at this AOC. 

• 1989: An PJ was performed to characterize the nature and distribution of sediment, soil, 
and groundwater contamination and evaluate site risks. 

• 1993: A supplemental RI was performed to further characterize sediment contamination 
and evaluate potential risks. 

• 1994: The National Guard Bureau, with the concurrence of EPA and MADEP, excavated 
coal, coal ash, and potentially contaminated soils from CY-4 and FTA-3 for use as 
subgrade fill during final capping of the main base landfill (LF-1). A total of 42,000 yd 3 of 
material, representing the majority of coal and coal ash at CY-4, was excavated to depths 



2-9 



of up to 15 ft. Additionally, soils at the FTA-3 location were also removed. This 
excavation was then backfilled with clean fill and covered with wood chips, restoring the 
land surface to approximately the original grade. 

• 1997: A feasibility study was performed to evaluate approaches to control potential site 
risks. 

• 2001: Surface and subsurface soil delineation sampling was conducted to determine the 
boundaries of soil excavation based on RALs. 

• 2001-2002: Excavations of contaminated soil were conducted at AOC SD-3/FTA-3/CY-4 
Detail A and B sites. Confirmation samples were collected, and restoration activities were 
conducted after excavation of each site. 

2.2.3 SD-4 

AOC SD-4 is a wooded drainage basin located in the southeastern section of MMR and extends 
from the flightline security area immediately east of Hangar 124 approximately 3,500 ft south 
toward Johns Pond (Figure 2-1). The source areas of AOC SD-4 addressed in this ESD are 
illustrated in Figure 2-4. The drainage basin, which became operational in 1950, received 
stormwater drainage from storm sewers that lead from Hangars 158, 128, 126, and 124, 
including the buildings, runways, ramps, and decks that serve the four hangars in addition to the 
former Building 123 pumphouse area. The drainage basin also reportedly received flow from 
numerous spills and liquids disposal during daily operations at these facilities. Significant 
historical events include the following: 

• 1968: An OWS was constructed in the drainage basin south of Reilly Road. 

• 1955-1970: Hangar 128 was used to maintain 18 to 21 aircraft. During that time, known 
quantities of solvents were released into the storm drain system. 

• 1978-1988: Hangar 126 was used by the USCG for aircraft maintenance. Periodic heating 
of the wing tanks of the aircraft resulted in numerous spills of AVGAS to the hangar deck; 
a portion of it was washed into the storm drain system. 



2-10 



• 1978: A spill of approximately 1,000 gal of AVGAS occurred outside the hangar; it was 
also flushed into the storm drain system. 

The primary environmental concerns at AOC SD-4 were the effects of chemical releases on 
surface soil, subsurface soil, surface water, and groundwater. It was estimated that approximately 
0.5 million to 1.4 million gal of petroleum distillate solvents was released to the SD-4 
stormwater drainage system from Hangar 158. These solvents, used in daily operations at 
support shops located in the hangar, were reportedly dumped into hangar deck drains connected 
to the storm drain system. 

The following investigations and remedial actions were conducted at AOC SD-4: 

• 1989-1991: An SI and a supplemental SI were performed to characterize the nature and 
distribution of sediment, soil, and groundwater contamination. 

• 1993-1994: An RI was performed to characterize the nature and distribution of sediment, 
soil, surface-water, and groundwater contamination and evaluate site risks. 

• 1999: As a pre-excavation sampling event, soil sampling was conducted in the drainage 
ditch north of Reilly Road to confirm the presence or absence of total petroleum 
hydrocarbon (TPH) contamination in soils at levels above soil target cleanup levels 
(STCLs). Concurrently, surface-water and sediment samples were collected at an 
upgradient pond/wetland area (south of Reilly Road). 

• 2001-2002: Surface water and sediment were sampled for ecological evaluation of a 
pond/wetland structure south of Reilly Road. 



2-11 



FIGURE 2-4 SD-4 OVERVIEW. 




2-12 



• 2002-2003: A screening-level ecological risk assessment and an ecological risk 
assessment were conducted to evaluate potential risks posed by inorganic constituents in 
hydric soils at the SD-4 wetland structure south of Reilly Road. 

• 2009: A groundwater sampling event was performed to determine whether or not residual 
concentrations of isomers of TMB remain in groundwater immediately downgradient from 
the former location of Building 123 pumphouse and associated underground storage tanks 
(USTs). 

2.2.4 SD-5/FS-5 

AOC SD-5/FS-5 is located in the central part of the MMR Cantonment Area between North 
Inner Road and Lingley Avenue on the north and south, respectively, and Base Runway No. 5 on 
the east, approximately 3,000 ft from the southern MMR boundary (Figure 2-1). The source 
areas of AOC SD-5/FS-5 addressed in this ESD occupy approximately 40 acres at the north end 
of a natural drainage swale that formerly extended southward for more than 10,000 ft toward 
Ashumet Pond (Figure 2-5). The Central Drainage Swale at AOC SD-5/FS-5 receives 
stormwater runoff from approximately 100 acres of paved runways and ramps through an 
extensive stormwater drainage system. The swale is unlined, and water that does not evaporate or 
infiltrate flows south to an unlined 1-acre stormwater infiltration basin. 

Possible contamination sources near SD-5 include an aircraft maintenance ramp, two 
UST/transfer systems (Aquafarms), the Nondestructive Inspection Laboratory (NDIL), and the 
Corrosion Control Shop. Significant historical events include the following: 

• 1950s: SD-5 began receiving stormwater runoff from a number of sources, including the 
Eastern and Western Aquafarms, the former NDIL, the Corrosion Control Shop, and the 
Permanent Field Training Site hangar. 

• Early 1960s: Three refueling aircraft were destroyed in a fire, resulting in the FS-5 fuel 
spill of up to 15,000 gal of AVGAS. The spill was washed into the storm drain. 



2-13 



1994: The NDIL and Corrosion Control Shop were demolished and removed. Two 12,000- 
gal USTs were removed from the Aviation Lubricating Oil (AVLUBE) area as part of the 
Fuel System Upgrade Program. 

1994-1995: A total of 17 USTs, including all six 25,000-gal tanks at the Western 
Aquafarm, all four 25,000-gal tanks at the Eastern Aquafarm, and seven 550-gal tanks 
associated with water separator control pits, were removed. 

1996: The NDIL leaching well and surrounding soil were removed as part of the Drainage 
Structure Removal Program (DSRP). 

The following investigations and remedial actions were conducted at AOC SD-4: 

1988: An SI was performed to assess the presence of soil and groundwater contamination. 

1989: An RI was performed to characterize the nature and distribution of sediment, soil, 
and groundwater contamination. 

1993: A supplemental RI was performed to further characterize contamination and 
evaluate site risks. 



2-14 



DETAIL B 
AREAS 3 AND 4 



DETAIL D 



DETAIL C 
AREA 5 




DETAIL A 
AREAS 1 AND 2 



DETAIL C 
AREA 9 



SCALE IN FEET 



1000' 



® 



8? 



LEGEND 



zz::~ ption 



REMEDIATION SITES 



SITE SAMPLING GRID 



POWER POLE 



FENCE LINE 



CONTOUR LINE 



BUILDING NUMBERS 



VEGETATION 




AIR FORCE CENTER FOR 
ENVIRONMENTAL EXCELLENCE 
322 EAST INNER ROAD 

OTIS ANGB, MA 02542 



FIGURE 1-2 
AOC SD-5/FS-5 
SITE MAP 



MASSACHUSETTS MILITARY RESERVATION 



SD-5/FS-5 REMEDIAL ACTION REPORT 



PROJECT CODE. 



"B 



CONTRACT CODE: 



MODIFIED BY: 

J.M ALVES 



AS SHOWN 



8 3 4. 



SHEET NO.: 

1 OF 1 



REVISCT 

1 



FIGURE 2-5 SD-5/FS-5 OVERVIEW 



2-15 



• 2000-2001. Surface and subsurface soil delineation sampling was conducted to determine 
the boundaries of soil excavation based on RALs. 

• 2001: Excavation and removal- and confirmation- sampling activities occurred at SD-5 
Detail B, Areas 3 and 4; SD-5 Detail C, Area 5; SD-5 Detail C, Areas 6, 7, and 8; Detail 
C, Area 9; and Detail D. 

• 2002-2003: SVE began operation at SD-5 Detail A on August 20, 2002, and completed 
operation and was shutdown on August 14, 2003. 

• 2004: Additional excavations were performed at SD-5 Details A and B. 
2.3 Selected Remedy 

This subsection describes the remedies that AFCEE originally committed to in the ROD for each 
AOC and additional information regarding changes to the remedies selected in the ROD, as 
applicable, resulting from the 2000 and/or 2003 ESDs (AFCEE 2000a; AFCEE 2003a). 

2.3.1 ROD CS-16/CS-17 Source Areas, Final, May 1999 

The selected remedy for CS-16/CS-17 was excavation, asphalt batching, onsite treatment, and 
offsite disposal. The major components of this remedy were excavation and onsite cold-mix 
asphalt batching of recyclable contaminated surface soils, with excavation and offsite disposal of 
nonrecyclable contaminated surface soils. This source control action was designed to address the 
principal threat at AOC CS-16/CS-17: the contamination of surface soils by organic compounds, 
pesticides/polychlorinated biphenyls (PCBs), and inorganic compounds at concentrations that 
pose an unacceptable risk to terrestrial ecological receptors through food-chain exposures. 
Because the remedy was a source area remedial action, it did not include a groundwater 
migration management component; however, groundwater monitoring annually for 5 years was 
included. Groundwater contamination beneath and downgradient of AOC CS-16/CS-17 was 
addressed as part of the Ashumet Valley groundwater plume cleanup. 

Excavated source area soils that were determined to exceed Toxicity Characteristic Leaching 
Procedure (TCLP) allowable concentrations and therefore deemed hazardous were disposed of 



2-16 



offsite in a RCRA Subtitle C treatment, storage, and disposal facility. Soils and sediments that 
were determined to be below TCLP allowable concentrations and therefore nonhazardous (and 
that were determined to contain contaminant concentrations below MADEP MCP Method 1 S- 
1/GW- 1 standards for pesticides and Massachusetts Permitted Soil Recycling Facility Summary 
Levels) would have been treated at the onsite cold-mix emulsion asphalt-batching plant. 

2.3.2 ROD AOC FTA-2/LF-2, PFSA/FS-10/FS-ll, SD-2/FS-8, SD-3/FTA-3/CY-4, SD-4, 
and SD-5/FS-5 Source Areas, Final, September 1998 

2.3.2.1 AOC SD-3/FTA-3/CY-4. The selected remedy for AOC SD-3/FTA-3/CY-4 is 
confirmation sampling with contingency of excavation and asphalt batching. This alternative 
included institutional and engineering controls to assess the adequacy of previous removal 
actions, limit exposure to site-related contaminants, and, if necessary, remove source-area soils 
exceeding cleanup criteria and treat the soils to reduce contaminant mobility. The risk 
assessment did not identify the need to clean up groundwater at this AOC; consequently, the 
remedy did not include a management-of-migration component. 

2.3.2.2 AOC SD-4. The selected remedy for AOC SD-4 was excavation and asphalt 
batching. This alternative included institutional and engineering controls for areas north of Reilly 
Road to limit exposure to site-related contaminants in soil and to reduce source-area soil 
contaminant concentrations to protective levels. For areas south of Reilly Road, this alternative 
provided sampling and engineering controls to assess the contribution of sediment contaminants 
to surface-water contamination, the potential bioavailability and toxicity of pond sediments, and, 
if necessary, removal of source-area sediments exceeding cleanup criteria (ROD did not specify 
a cleanup level) and treatment of excavated material to reduce contaminant mobility. The risk 
assessment did not identify the need to clean up groundwater at this AOC; consequently, the 
remedy did not include a management-of-migration component. 

2.3.2.3 AOC SD-5/FS-5. The selected remedy for AOC SD-5/FS-5 was excavation and 
asphalt batching. This alternative included institutional and engineering controls to limit 
exposure to site-related contaminants and to reduce source-area contaminant concentrations to 
protective levels. The remedy did not include a management-of-migration component. 
Groundwater contamination attributed to AOC SD-5/FS-5 was addressed by the SD-5 North 



2-17 



Groundwater Plume Extraction, Treatment, and Reinjection System and the SD-5 South 
Recirculating Well System. 

2.3.3 Final 2000 ESD, October 2000 

The 2000 ESD (AFCEE 2000a) was prepared to document a change to the remedy selected for 
AOC SD-5 in the Six-AOC ROD (AFCEE 1998). The ESD added a drainage swale that had 
been considered part of the CS-2 Study Area to the horizontal footprint of AOC SD-5/FS-5 
(Figure 2-5, shown as Detail D). In the process of preparing a draft decision document proposing 
"No Further Action" on the CS-2 (CDM Federal Programs Corporation [CDM] 1997), AFCEE 
noted that a drainage swale at CS-2 still contained elevated levels of contaminants above STCLs 
that were similar to those found within AOC SD-5. Because the horizontal extent of 
contamination at SD-5 was to be further delineated in 2000, and remediation was scheduled to 
follow this delineation effort, it was more practical to add the CS-2 drainage swale to the future 
delineation and remediation efforts at SD-5. In addition, the No Further Action decision 
document for CS-2 could be finalized immediately, because residual risk associated with the 
remainder of this study area was within regulatory limits. The other AOCs, including FS-5, were 
not affected by the 2000 ESD. 

2.3.4 Final 2003 ESD, January 2003 

The 2003 ESD (AFCEE 2003a) was prepared to document changes to the selected remedy for 
several sites in the SARAP, including sites covered under the CS-16/CS-17 ROD (AFCEE 1999) 
and the Six-AOC ROD (AFCEE 1998), including SD-2/FS-6/FS-8 and SD-3/FTA-3/CY-4. Four 
changes were made to the selected remedy presented in the two SARAP RODs: 

• Establishment of RALs for certain inorganic chemicals, PCBs, and petroleum 
hydrocarbons to replace cleanup levels in the RODs (see Table 2-1) 

• Removal of the asphalt-batching component from the selected remedies 

• Expansion of offsite disposal options to include RCRA Subtitle D facilities 



2-18 



• Exercising the contingency remedy at AOC SD-3/FTA-3/CY-4 to include excavation and 
offsite disposal. 

The changes listed above did not affect the selected remedy for SD-4 or SD-5/FS-5. 

The 2003 ESD RALs for inorganic chemicals and petroleum hydrocarbons superseded the 
cleanup levels for identified COCs presented in SARAP controlling documents, which are based 
on STCLs used for the DSRP. The 2003 ESD incorporated the following changes: 

• In 2000, AFCEE, with concurrence from EPA and MADEP, revised ecological risk-based 
STCLs for inorganic chemicals in a technical memorandum (AFCEE 2000b) 

• In 2002, AFCEE revised phytotoxicity and invertebrate STCLs for several inorganics in an 
addendum to the technical memorandum (Portage 2002) 

• AFCEE adapted the EPA screening level guidance for Superfund sites as the RAL for 
PCBs 

• MADEP developed generic soil cleanup standards for the hydrocarbon fractions using the 
EPH/VPH analytical procedures (MADEP 1994). 

The development of a RAL included a comparison of the revised terrestrial vertebrate receptor 
STCLs with the terrestrial plant STCL and terrestrial invertebrate STCL. The lowest STCL was 
then compared to the MMR-specific background. The higher of the two values was selected as 
the RAL protective of all ecological receptors. As a result of these changes to the CS-16/CS-17 
ROD and the Six-AOC ROD, the 2003 ESD provided revised and new RALs for the COCs listed 
in Tables 2-1 and 2-2, respectively. 

The 2003 ESD documents the removal of the asphalt batching component because of 
contaminated soils from SD-3/FTA-3/CY-4 and CS-16/CS-17 not being amenable for asphalt 
batching due to physical and/or chemical properties (i.e., high organic content or contaminant 
concentrations greater than MADEP soil acceptance criteria for recycling facilities). The 
remaining volume of contaminated soils from SD-2/FS-6/FS-8 that could be asphalt batched did 
not justify the capital cost of an onsite asphalt batching unit. 



2-19 



The 2003 ESD also documents the decision to allow for flexibility in offsite soil disposal on the 
grounds that recent waste characterization efforts indicate that none of the contaminated soil 
excavated at AOCs SD-2/FS-6/FS-8, SD-3/FTA-3/CY-4, and CS-16/CS-17 addressed in the 
2003 ESD was RCRA hazardous waste. Therefore, this material could be disposed of at RCRA 
Subtitle D facilities. 

The selected remedy at AOC SD-3/FTA-3/CY-4 is confirmation sampling with the contingency 
of excavation and asphalt batching. The 2003 ESD documents the exercising of the excavation 
component of the contingency remedy. Evaluation of analytical data for this site indicated that 
the soil at this site is considered nonrecyclable and therefore shall be disposed of at an offsite 
disposal facility instead of being asphalt batched as the original contingency required. 



2-20 



Table 2-1 Summary of changes in cleanup levels and basis for selection in the 2003 ESD. 



coc 


SARAP ROD Cleanup Level 
(mg/kg)/Basis 


2003 ESD RAL (mg/kg)/ 
Basis 


Arsenic 


3.6 (MMR background) 


7.1 (Lowest ecological, 
mammal ) 


Cadmium 


1 .5 (MMR background) 


1.8 (Lowest ecological, bird) 


Chromium 


6.8 (MMR background) 


19.0 (Camp Edwards/MMR 
DacKgrouno ) 


copper 


ly.j ^i^owesi ecoiogicai, uircij 


oi.u geological, 
invertebrates) 


Lead 


15.8 (Lowest ecological, bird) 


99.0 (MADEP background) 


Mercury 


1 .46 (Lowest ecological, bird) 


0.18 (Lowest ecological) 


Vanadium 


15.2 (MMR background) 


47.0 (Lowest ecological) 


Zinc 


io.u ^iviivirv oacKgrounoj 


r\ X fill All rapf 1 /A m /"» O 1 1 

oo.u ^i^owesi ecoiogicaij 


PCBs 


0.158 (Human health) 


1 .0 (EPA human health risk) 


TPH a 


500 (Outside the flightline, 
MCP S-l/GW-1) 


1,000 (MCP S-l/GW-1) 


a. See Table 2-2 for petroleum hydrocarbon fractions. 



2-21 



Table 2-2 MCP S-l/GW-1 standards for petroleum hydrocarbons selected in the 2003 ESD. 



coc 


SARAP ROD Cleanup Level 
(mg/kg)/Basis 


2003 ESD RAL 
(mg/kg)/Basis 


Cs-Cg Aliphatic hydrocarbons 


Not identified 


100 (MCP S-l/GW-1) 


C9-C12 Aliphatic hydrocarbons 


Not identified 


1,000 (MCP S-l/GW-1) 


C9-C18 Aliphatic hydrocarbons 


Not identified 


1,000 (MCP S-l/GW-1) 


C19-C36 Aliphatic hydrocarbons 


Not identified 


3,000 (MCP S-l/GW-1) 


C9-C10 Aromatic hydrocarbons 


Not identified 


100 (MCP S-l/GW-1) 


C11-C22 Aromatic hydrocarbons 


Not identified 


200 (MCP S-l/GW-1) 



2-22 



3.0 BASIS FOR THE EXPLANATION OF SIGNIFICANT DIFFERENCES 



This ESD describes changes to the remedies for CS-16/CS-17, SD-3/FTA-3/CY-4, SD-4, and 
SD-5/FS-5. Changes include following: 

• Establishment of new RALs for surface soil (0-2 ft below ground surface [bgs]) for some 
COCs and for contaminants not considered COCs in the RODs (discussed in Subsection 
3.1) 

• Removal of the potential sediment excavation requirement from the selected remedy at 
SD-4 (discussed in Subsection 3.2) 

• Removal of the asphalt-batching component from the selected remedy of SD-5/FS-5 
(discussed in Subsection 3.3) 

• Implementation of an SVE system to treat TCE and PCE in subsurface soil at SD-5 Detail 
A (discussed in Subsection 3.4) 

• Expansion of offsite disposal options for excavated soil from AOC SD-5/FS-5 to include 
RCRA Subtitle D facilities (discussed in Subsection 3.5) 

The level of protection (i.e., risk reduction) that the remedies provide will not be impacted by the 
changes in the remedies. 

The basis for each of the significant differences listed above is described below. 
3.1 Establishment of New Surface Soil Remedial Action Levels 

This ESD uses the same basis as the 2003 ESD for establishment of new surface soil RALs for 
inorganic and petroleum hydrocarbon COCs, i.e., RALs were selected through a systematic 
review of revised STCLs, phytotoxicity and invertebrate screening values, and background 
concentrations. Those RALs that are selected or changed through this ESD are discussed below, 
by COC. Those COCs not specifically identified below are adopted in this current ESD 
unchanged from the 2003 ESD. 



3-1 



Mercury - Mercury was historically found at the former sludge disposal area of (AOC CS-16/ 
CS-17 Detail C) at elevated levels (AFCEE 2003c). Because the historic samples were 
composites, the detected mercury levels were not used in the risk assessment and mercury was 
not identified as a COC in the ROD. However, delineation sampling included both total mercury 
and methyl mercury analysis to ensure that there were no unacceptable human and ecological 
risks remaining. 

The intent of the total mercury and methyl mercury analysis was to determine whether or not the 
mercury present at the former sludge disposal area (CS-16/CS-17 Detail C) was the more toxic 
form of mercury (i.e., mono-methyl mercury) or elemental mercury. The mercury RAL for 
protection of ecological receptors is 0.18 mg/kg, which is based on the mono-methylated form. 
Delineation results indicated that mono-methyl mercury was present at trace concentrations, well 
below the MMR RAL; however, concentrations of total mercury exceeding the MADEP Landfill 
Reuse Level (10 mg/kg) were excavated due to the presence of other compounds exceeding the 
RALs (AFCEE 2003c). Approximately 3,286 cubic yards of contaminated soil was removed 
from CS-16/CS-17 Detail C either as excavated soil or removal of existing soil piles. 
Delineation sampling indicated approximately 70% of the contaminated soil included total 
mercury in excess of the 10 mg/kg reuse level. 

Based on the historical investigations and remedial action activities, this ESD proposes to add 
mono-methyl mercury and total mercury as COCs and their associated RALs for AOC CS- 
16/CS-17. Adopting the new COCs and RALs does not change the protectiveness of the remedy. 

Petroleum hydrocarbons - The cleanup level for TPH was amended by incorporating the most 
current MCP S-l/GW-1 standards for EPH/VPH. MADEP has re-evaluated MCP S-l/GW-1 
standards since 2003. The new MCP S-l/GW-1 standards became effective on February 14, 
2008; see 310 Code of Massachusetts Regulations (CMR) 40.0975(6)(1) (MADEP 2012). The 
MCP S-l/GW-1 standard for C19 through C36 aliphatic hydrocarbons has increased from 2,500 to 
3,000 mg/kg. The MCP S-l/GW-1 standard for Cn through C22 aromatic hydrocarbons has 
increased from 200 to 1,000 mg/kg. The new MCP S-l/GW-1 standards do not change the 
protectiveness of the remedy. 



3-2 



Dieldrin - Dieldrin was identified as a COC in the CS-16/CS-17 ROD with a RAL of 
0.035 mg/kg, which is based on the lowest of risk/hazard-equivalent concentrations for mammals 
and birds listed in Appendix F, Table F-2, of the MMR Risk Assessment Handbook (RAH) 
(Automated Sciences Group [ASG] 1994). The new surface soil RALs are based on the most 
stringent value of the following: (1) phy to toxicity critical soil concentration included in 
Appendix O, Table 0-3, of the MMR RAH; (2) lowest of ecological risk-based concentrations 
for white-footed mouse, cardinal, and red fox included in Appendix F, Table F-2, of the MMR 
RAH; (3) Outside of the Flightline (i.e., residential) Tier I risk/hazard evaluation concentrations 
included in Appendix F, Table F-l, of the MMR RAH; and (4) the current MCP S-l/GW-1 
standard (MADEP 2012). Table 3-1 shows the selection process and the resulting new surface 
soil RAL for dieldrin. 

Polycyclic aromatic hydrocarbons (PAHs) - PAHs such as chrysene, fluoranthene, 
phenanthrene, and pyrene were not identified as COCs in the RODs, 2000 ESD, and 2003 ESD 
for any of the AOCs affected by this ESD. As a component of the selected remedy (i.e., to collect 
and analyze samples for SVOCs and inorganics) for AOC SD-3/FTA-3/CY-4, delineation soil 
samples were analyzed for PAHs and metals. The 2000 ESD removed the drainage swale from 
CS-2 and added it to AOC SD-5/FS-5 and also proposed soil sampling of the former CS-2 
drainage ditch. Samples were to be analyzed for pesticides, PCBs, metals, and SVOCs. For 
delineation purposes, exceedances of ecological risk-based DSRP STCLs were to be considered 
COCs for SD-3/FTA-3/CY-4 and SD-5/FS-5. The ecological risk-based DSRP STCLs for 
chrysene, fluoranthene, phenanthrene, and pyrene were based on the lowest of risk/hazard- 
equivalent concentrations for mammals and birds listed in Appendix F, Table F-2, of the MMR 
RAH. 

New surface soil RALs for chrysene, fluoranthene, phenanthrene, and pyrene are based on the 
most stringent value of the following: (1) phytotoxicity critical soil concentration included in 
Appendix O, Table 0-3, of the MMR RAH; (2) lowest of ecological risk-based concentrations 
for white-footed mouse, cardinal, and red fox included in Appendix F, Table F-2, of the MMR 
RAH; (3) Outside of the Flightline (i.e., residential) Tier I risk/hazard evaluation concentrations 
included in Appendix F, Table F-l, of the MMR RAH; and (4) the current MCP S-l/GW-1 



3-3 



standard (MADEP 2012). Table 3-1 shows the selection process and the resulting new surface 
soil RALs for organic COCs. 



3-4 



Table 3-1 Selection process for new surface soil RALs for organic contaminants. 



PAP 

cue 


Phytotoxicity 
Critical 

Concentration 
(mg/kg) 


Lowest 
Ecological 
Risk 
(mg/kg) 


Outside the 
Flightline 

Tier I 
(mg/kg) 


MCP 
S-l/GW-1 

(mg/kg) 


2013 Surface 
Soil RALs 
(mg/kg) 


i_y 1 1 iLii 111 


1 39 


44 


1 33 


OS 


05 


Chrysene 


7.82 


8.86 


86.0 


70.0 


7.82 


Fluoranthene 


7.26 


105 


2,200 


1,000 


7.26 


Phenanthrene 


4.16 


7.47 


2,200 


10 


4.16 


Pyrene 


7.08 


65.7 


1,650 


1,000 


7.08 


Bold = The most stringent value selected as the new surface soil RALs in this 2013 ESD. 



Table 3-2 summarizes new RALs for surface soil (0-2 ft bgs) for some COCs and for 
contaminants not considered COCs in the CS-16/CS-17 ROD and the Six-AOC ROD. Changes 
to a specific AOC are included in Subsection 4.1 of this ESD. 

Table 3-2 Additional and revised RALs (0-2 ft bgs). 



coc 


ROD RAL (mg/kg)/Basis 


2013 RAL (mg/kg)/Basis 


Arsenic 


3.6 (MMR background) 


7.1 (Lowest ecological, 
mammal) 


Cadmium 


1 .5 (MMR background) 


1.8 (Lowest ecological, bird) 


Chromium (total) 


6.8 (MMR background) 


19.0 (Camp Edwards/MMR 
background) 


Copper 


19.3 (Lowest ecological, 
bird) 


61.0 (Ecological, invertebrates) 



3-5 



Lead 


15.8 (Lowest ecological, 
bird) 


99.0 (MADEP background) 


Mercury, methyl 


Not identified 


0.18 (Lowest ecological, 
mammal) 


Mercury, total 


Not identified 


10.0 (MADEP landfill reuse 
level) 


Nickel 


Not identified 


20.0 (MCP S-l/GW-1 standard) 


Vanadium 


15.2 (MMR background) 


47.0 (Lowest ecological, 
mammal) 


Zinc 


16.0 (MMR background) 


68.0 (Lowest ecological, bird) 


Dieldrin 


Not identified 


0.05 (Current MCP S-l/GW-1 
s Ldncidrci ) 


^nryseiie 


i\ioi lueniiiieci 


u.ozj ^ideological, Diruj 


r luordninene 


inoi lcienuiieci 


/.Ol ^£/C010glCdl, DirilJ 


Phenanthrene 


Not identified 


0.625 (Ecological, bird) 


Pyrene 


Not identified 


4.69 (Ecological, bird) 


TPH 


500 (Outside the Flightline, 
MCP S-l/GW-1) 


1,000 (Current MCP S-l/GW-1 
standard) 



3-6 



Aliphatic Hydrocarbons 


Cs-Cg Aliphatic hydrocarbons 


Not identified 


100 (Current MCP S-l/GW-1 
standard) 


C9-C12 Aliphatic 
hydrocarbons 


Not identified 


1,000 (Current MCP S-l/GW-1 
standard) 


C9-C18 Aliphatic 
hydrocarbons 


Not identified 


1,000 (Current MCP S-l/GW-1 
standard) 


C19-C36 Aliphatic 
hydrocarbons 


Not identified 


3,000 (Current MCP S-l/GW-1 
standard) 


Aromatic Hydrocarbons 


C9-C10 Aromatic 
hydrocarbons 


Not identified 


100 (Current MCP S-l/GW-1 
standard) 


C11-C22 Aromatic 
hydrocarbons 


Not identified 


1,000 (Current MCP S-l/GW-1 
standard) 



3.2 Removal of the Potential Sediment Excavation Requirement from the Selected 
Remedy at SD-4 

The remedy in the SD-4 ROD included the requirement for sampling and engineering controls to 
assess the contribution of sediment contaminants to surface-water contamination, the potential 
bioavailability and toxicity of pond sediments, and, if necessary, removal of source-area 
sediments exceeding cleanup criteria (ROD did not specify a cleanup level) and treatment of 
excavated material to reduce contaminant mobility in the area south of Reilly Road. The 
required sampling and evaluation was conducted between 2001 and 2003 and concluded that 
although there are levels of inorganic COPCs present in hydric soils in the wetland portion of 
SD-4, these levels are not likely to have a significant negative impact on the wetland plant and 
invertebrate communities, and wetland receptors (e.g. plants and terrestrial invertebrates) in SD- 
4 are not likely to be at risk from exposure to inorganic compounds in hydric soil at this site 



3-7 



(AFCEE 2003b). Additionally, the risk evaluation indicated that little to no significant potential 
risks to vertebrate wildlife are likely from exposure to COPCs in SD-4 hydric soil (AFCEE 
2003d). 

3.3 Removal of the Asphalt-Batching Component from the Selected Remedy of AOC 
SD-5/FS-5 

The remedy presented in the SD-5/FS-5 ROD is excavation and onsite cold-mix asphalt batching 
of recyclable contaminated soils. The basis for removal of the asphalt-batching component from 
the SD-5/FS-5 remedy in this ESD is that the volume of contaminated soil from SD-5/FS-5 was 
less than previously estimated and resulted in a cost difference that favored offsite disposal. 

3.4 Implementation of an SVE System to Treat TCE and PCE in Subsurface Soil at 
AOC SD-5 Detail A 

Sampling was conducted between December 2000 and January 2001 at AOC SD-5 Detail A to 
determine the lateral and vertical extent of metals and VOC contamination to 4 ft bgs. Sampling 
was performed on a 50- x 50-ft grid pattern. Concentrations of TCE slightly above the STCL of 
10 ug/kg were detected in grids DD21, EE21, and FF21. The highest concentration was 25.9 
ug/kg detected in grid EE21 at a depth of 2 ft bgs. Because there were detections of TCE above 
the STCL, additional sampling was required to fully characterize the lateral and vertical extent of 
contamination at SD-5 Detail A. 

Subsurface samples were collected from June 2001 through November 2001 to determine the 
vertical extent of chlorinated VOC contamination at SD-5 Detail A. Eight locations had 
detections above the leaching-based STCLs for PCE and TCE. Contamination is generally 
confined to grids AA19 and BB19 and between 6 and 20 ft bgs. 

Because the depth of contamination was greater than expected, the method of remediation was 
reevaluated. Excavations to depths of 20 ft have sloping requirements that significantly increase 
the size of excavation. SVE treatment, however, treats the soil in place and is generally the 
presumptive remedy for subsurface VOC contamination. In this instance, SVE was found to be 
preferable, and AFCEE, in coordination with the EPA and MADEP, selected SVE as the method 
for treatment (AFCEE 2005b). 



3-8 



Results of the delineation sampling were used to design an SVE system. The optimized vapor 
extraction treatment system for the SD-5 site consisted of two extraction wells located at the 
center of the grids AA19 and BB19, with a 10-ft well screen in the vadose zone from 8 to 18 ft 
bgs. The system is an extension of the treatment system used at AOC FTA-2/LF-2. Appendix C 
of AFCEE (2005b) describes the operation and results of the SVE system at SD-5 which 
operated from 20 Aug 2002 to 14 August 2003 and removed approximately 5 pounds of VOCs. 

3.5 Expansion of Offsite Disposal Options for Excavated Soil from AOC SD-5/FS-5 to 
Include RCRA Subtitle D Facilities 

This ESD amends the offsite disposal component by providing flexibility for disposal of 
nonhazardous wastes (i.e., contaminated soil) from AOC SD-5/FS. Excavated soils from AOC 
SD-5/FS-5 were transported to and stockpiled at the Central Storage Area. Stockpile soil 
sampling was required to fulfill the waste characterization requirements for disposal at the 
landfill. Waste characterization efforts indicated that none of the contaminated soil excavated 
from AOC SD-5/FS-5 was a RCRA hazardous waste. Results, which are presented in Appendix I 
of AFCEE (2005b), were below RCRA TCLP levels. 

Because the stockpiled AOC SD-5/FS-5 soil was already shipped as a nonhazardous material 
under a MADEP bill of lading to the Taunton Landfill in Taunton, Massachusetts, and the 
Thatcher Street Landfill in Brockton, Massachusetts, it is appropriate to expand offsite disposal 
options to include facilities permitted to accept only nonhazardous wastes (i.e., RCRA Subtitle D 
landfills). 



3-9 



4.0 DESCRIPTION OF SIGNIFICANT DIFFERENCES 



This section describes the significant differences between the original selected remedy as 
presented in the applicable RODs and the two subsequent ESDs (2000 ESD and 2003 ESD) and 
the actions proposed in this ESD. 

4.1 Establishment of New Surface Soil Remedial Action Levels 

Table 4- 1 presents a comparison of original (ROD RALs) and revised or new RALs for AOCs 
CS-16/CS-17, SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5 affected by this ESD. Table 4-1 
separates the AOCs according to their respective RODs. 



Table 4-1 Comparison of original (ROD RALs) and revised or new RALs for AOCs CS-16/CS- 
17, SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5 affected by this ESD. 



coc 


ROD RAL (mg/kg) 


New RAL (mg/kg) 


ROD AOC CS-16/CS-17 


Dieldrin 


0.035 


0.05 


Mercury, mono-methyl 


Not identified 


0.18 


Mercury, total 


Not identified 


10.0 


ROD AOC SD-3/FTA-3/CY-4 


Chrysene 


Not identified 


0.625 


Phenanthrene 


Not identified 


0.625 


ROD AOC SD-4 


Arsenic 


Not identified 


7.1 


Cadmium 


Not identified 


1.8 


Chromium (total) 


Not identified 


19.0 


Lead 


Not identified 


99.0 


Nickel 


Not identified 


20.0 (MCP S-l/GW-1 



4-1 







standard) 


Vanadium 


Not identified 


47.0 


C 5 -C 8 Aliphatic 
hydrocarbons 


l,200 a 


100 


C9-C12 Aliphatic 
hydrocarbons 


l,200 a 


1,000 


C13-C18 Aliphatic 
hydrocarbons 


l,200 a 


1,000 


C19-C36 Aliphatic 
hydrocarbons 


l,200 a 


3,000 


C9-C10 Aromatic 
hydrocarbons 


l,200 a 


100 


C11-C22 Aromatic 
hydrocarbons 


l,200 a 


1,000 


ROD AOC SD-5/FS-5 


Arsenic 


Not identified 


7.1 


Chromium (total) 


6.8 


19.0 


Copper 


19.3 


61.0 


Lead 


15.8 


99.0 


Mercury 


1.48 


10.0 


Vanadium 


Not identified 


47.0 


Zinc 


16.0 


68.0 


Dieldrin 


Not identified 


0.05 


Chrysene 


Not identified 


0.625 


Fluoranthene 


Not identified 


7.81 


Pyrene 


Not identified 


4.69 


Phenanthrene 


Not identified 


0.625 



4-2 



TPH 


Not identified 


1,000 


C 5 -C 8 Aliphatic 
hydrocarbons 


Not identified 


100 


C9-C12 Aliphatic 
hydrocarbons 


Not identified 


1,000 


C13-C18 Aliphatic 
hydrocarbons 


Not identified 


1,000 


C19-C36 Aliphatic 
hydrocarbons 


Not identified 


3,000 


C9-C10 Aromatic 
hydrocarbons 


Not identified 


100 


C11-C22 Aromatic 
hydrocarbons 


Not identified 


1,000 


a. Soil-only cleanup level based on inside-the-flightline TPH STCL. No cleanup levels were 
developed for sediment and surface water in the ROD for SD-4. 



4-3 



4.2 Removal of the Potential Sediment Excavation Requirement from the Selected 
Remedy SD-4 

The remedy presented in the SD-4 ROD included the requirement for sampling and engineering 
controls to assess the contribution of sediment contaminants to surface-water contamination, the 
potential bioavailability and toxicity of pond sediments, and, if necessary, removal of source- 
area sediments exceeding cleanup criteria (ROD did not specify a cleanup level) and treatment of 
excavated material to reduce contaminant mobility in the area south of Reilly Road. This ESD 
removes the requirement for potential sediment excavation south of Reilly Road because 
sampling and associated risk assessments indicate no unacceptable ecological risk. 

4.3 Removal of the Asphalt-Batching Component from the Selected Remedy of AOC 
SD-5/FS-5 

The remedy presented in the SD-5/FS-5 ROD is excavation and onsite cold-mix asphalt batching 
of recyclable contaminated soils and excavation and offsite disposal of nonrecyclable 
contaminated soils to be disposed of at a facility permitted to treat and/or dispose of RCRA 
hazardous waste. This ESD removes the asphalt-batching component from the SD-5/FS-5 
remedy, because contaminated soil from SD-5/FS-5 was not amenable for asphalt batching (i.e., 
nonrecyclable). 

4.4 Implementation of an SVE System to Treat TCE and PCE in Subsurface Soil at 
AOC SD-5 Detail A 

The results of subsurface samples collected from June 2001 through November 2001 to 
determine the vertical extent of chlorinated VOC contamination at SD-5 Detail A concluded that 
the depth of contamination was greater than expected, and the method of remediation was 
reevaluated. Excavations to depths of 20 ft have sloping requirements that significantly increase 
the size of excavation. SVE treatment, however, treats the soil in place and is generally the 
presumptive remedy for subsurface VOC contamination. In this instance, SVE was found to be 
preferable, and AFCEE, in coordination with the EPA and MADEP, selected SVE as the method 
for treatment (AFCEE 2005b). Therefore, this ESD documents the implementation of the SVE 
system to treat TCE and PCE in subsurface soil at AOC SD-5 Detail A. 



4-4 



4.5 Expansion of Offsite Disposal Options for Excavated Soil from AOC SD-5/FS-5 to 
Include RCRA Subtitle D Facilities 

This ESD amends the offsite disposal component by providing flexibility for disposal of 
nonhazardous wastes (i.e., contaminated soil) from AOC SD-5/FS-5. Waste characterization 
efforts indicated that none of the contaminated soil excavated from AOC SD-5/FS-5 was a 
RCRA hazardous waste. Because the stockpiled AOC SD-5/FS-5 soil was already shipped as a 
nonhazardous material under a MADEP bill of lading to the Taunton Landfill in Taunton, 
Massachusetts, and the Thatcher Street Landfill in Brockton, Massachusetts, it is appropriate to 
expand offsite disposal options to include facilities permitted to accept only nonhazardous wastes 
(i.e., RCRA Subtitle D landfills). 



4-5 



5.0 STATUTORY DETERMINATION 

This ESD modifies multiple remedies for several sites and is consistent with CERCLA §121 and, 
to the extent practicable, the NCP. The modifications: 

• Are protective of human health and the environment 

• Comply with federal and Commonwealth of Massachusetts requirements that are legally 
applicable or relevant and appropriate to the remedial action and that are cost-effective 

• Are the result of successfully implementing remedial actions using permanent solutions 
and alternative treatment technologies to the maximum extent practicable 

• Reduce administrative costs and unnecessary regulatory burden. 



5-1 



6.0 REFERENCES 



40 CFR 300, 2010, "National Oil and Hazardous Substances Pollution Contingency Plan," Code 
of Federal Regulations, Office of the Federal Register, July 1, 2010. 

42 USC § 6901 et seq., 1976, "Resource Conservation and Recovery Act of 1976," as amended. 

42 USC § 9601, et seq., 1980, "Comprehensive Environmental Response, Compensation, and 
Liability Act of 1980," as amended. 

AFCEE, 1998, Record of Decision, Six Areas of Contamination FTA-2/LF-2, PFSA/FS-10/FS- 
11, SD-2/FS-6/FS-8; SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5 Source Areas, 
AFCEE/MMR IRP, Otis ANG Base, Massachusetts, September 1998. 

AFCEE, 1999, Record of Decision, Area of Contamination CS-16/CS-17 Source Areas, 
AFCEE/MMR IRP, Otis ANG Base, Massachusetts, May 1999. 

AFCEE, 2000a, Explanation of Significant Differences to the Final Record of Decision, Areas of 
Contamination FTA-2/LF-2, PFSA/FS-10/FS-22, SD-2/FS-6/FS-8, SD-3/FTA-3/CY-4, SD- 
4, and SD-5/FS-5 Source Areas, AFCEE/MMR IRP, Otis ANG Base, Massachusetts, 
October 2000. 

AFCEE, 2000b, Final Technical Memorandum Revised Ecological Soil Target Cleanup Levels 
for Inorganics, AFCEE/MMR IRP, Otis ANG Base, Massachusetts, December 2000. 

AFCEE, 2003a, Explanation of Significant Differences Areas of Contamination, CS-10 (A, B & 
E), CS-16/CS-17, FS-9, SD-2/FS-6/FS-8, and SD-3/FTA-3/CY-4, AFCEE/MMR IRP, Otis 
ANG Base, Massachusetts, January 2003. 

AFCEE, 2003b, Final Revised Screening Level Ecological Risk Assessment, Area of Concern 
SD-4, AFCEE/MMR IRP, Otis ANG Base, Massachusetts, January 2003 . 

AFCEE, 2003c, Final Remedial Action Report Area of Contamination CS-16/CS-17, 
AFCEE/MMR IRP, Otis ANG Base, Massachusetts, April 2003. 



6-1 



AFCEE, 2003d, Final Ecological Risk Assessment - Addendum, Area of Concern SD-4, 
AFCEE/MMR IRP, Otis ANG Base, Massachusetts, December 2003. 



AFCEE, 2004, Memorandum of Resolution, Air Force Center for Environmental Excellence 
Resolution of EPA Comments on the Draft Proposed Plan for Eastern Briarwood, Western 
Aquafarm, and Storm Drain-5 Groundwater, December 2004. 

AFCEE, 2005b, Final AOC Storm Drain-5/Fuel Spill-5 Source Area Remedial Action Report, 
AFCEE/MMR IRP, Otis ANG Base, Massachusetts, September 2005. 

AFCEE, 2006, Final Record of Decision for Groundwater at Eastern Briarwood, Western 
Aquafarm, and Storm Drain-5, AFCEE/MMR IRP, Otis ANG Base, Massachusetts, 
September 2006. 

AFCEE, 2008b, Final 3rd Five-Year Review, 2002-2007, AFCEE/MMR Installation Restoration 
Program, Otis ANG Base, Massachusetts, September 2008. 

ASG, 1994, Risk Assessment Handbook, Massachusetts Military Reservation, Cape Cod, 
Massachusetts, Hazardous Waste Remedial Actions Program, Lockheed Martin Energy 
Systems, Inc., Oak Ridge, Tennessee, September 1994. 

CDM, 1997, Decision Document for Chemical Spill (CS) Site No. 2, IRP, MMR, prepared for 
HAZWRAP, Cambridge, Massachusetts, March 1997. 

EPA, 1999, A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other 
Remedy Selection Decision Documents, EPA Office of Solid Waste and Emergency 
Response, EPA 540-R-98-031, OSWER 9200.1-23P, PB98-963241, July 1999. 

EPA, 2001, Comprehensive Five-Year Review Guidance, U.S. Environmental Protection 
Agency, Office of Emergency and Remedial Response, EPA 540-R-01-007, OSWER No. 
9355.7-03B-P, June 2001. 

EPA, 2012, Regional Screening Level (RSL) Resident Soil Supporting Table, May 2012 
http ://www .epa. go v/region9/superfund/prg/ , Web page accessed May 2012. 



6-2 



MADEP, 1994, Background Documentation for the Development of the MCP Numerical 
Standards, Bureau of Waste Site Cleanup and Office of Research and Standards, April 
1994. 

MADEP, 2002, Technical Update: Background Levels of Polycyclic Aromatic Hydrocarbons 
and Metals in Soil, Updates: Section 2.3 Guidance for Disposal Site Risk Characterization 
In Support of the Massachusetts Contingency Plan (1992), 
http://www.mass.gov/dep/cleanup/laws/backtu.pdf, May 2002. 

MADEP, 2010, Massachusetts Contingency Plan, 310 CMR 40.0000, 
http://www.mass.gov/dep/cleanup/laws/mcpsuba.htm, Web site accessed March 25, 2010. 

MADEP, 2012, MCP S-l/GW-1 Soil Standards, Massachusetts Department of Environmental 
Protection, 310 CMR 40.0975(6)(a), http://www.mass.gov/dep/cleanup/laws/0975_6a.htm, 
Web site accessed May 2012. 

Portage, 2002, Addendum to Technical Memorandum Revised Ecological Soil Target Cleanup 
levels for Inorganics, AFCEE/MMR IRP, Otis ANG Base, Massachusetts, September 
2002. 



6-3 



APPENDIX A 
MassDEP Concurrence Letter 




One Winter Street Boston, MA 02108 • 617-292-5500 



Department of Environmental Protection 



Commonwealth of Massachusetts 

Executive Office of Energy & Environmental Affairs 



OEVAL L PATRICK 
Governor 



RICHARD K. SULLIVAN JR. 



TIMOTHY P MURRAY 
Lieutenant Governor 



KENNETH L KIMMELL 
Commissioner 



September 30,2013 



James T. Owens 111, Director 

Office of Site Remediation and Restoration 

U.S. Environmental Protection Agency, Region I 

5 Post Office Square, Suite 100 

Boston, MA 02109-3912 



RE: 



BOURNE 

Release Tracking Number: 4-0000037 
Joint Base Cape Cod (JBCC) 
Explanation of Significant Differences, Areas 
of Contamination C5-16/CS-17, SD-3/FTA- 
3/CY-4, SD-4, and SD-5/FS-5, Concurrence 



Dear Mr. Owens: 

The Massachusetts Department of Environmental Protection (MassDEP) has reviewed the document 
entitled "Explanation of Significant Differences, Areas of Contamination CS-16/CS-17, SD-3/FTA-3/CV- 
4, SD-4, and SD-5/FS-5" (the ESD), dated August 2013. The ESD was prepared by the Air Force Civil 
Engineer Center (AFCEC) (formerly Air Force Center for Engineering and the Environment (AFCEE)) at the 
Joint Base Cape Cod (JBCC) - (formerly the Massachusetts Military Reservation (MMR)) in accordance 
with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The ESD 
was prepared to document changes to the language in the decision documents for the following 
Installation Restoration Program (IRP) Areas of Contamination (AOCs): Chemical Spill {CS}-16,C$-17, 
Storm Drainage (SD)-3, Fire Training Area {FTA)-3, Coal Yard (CY)-4, SD-4, SD-5, and Fuel Spill (FS)-5. 

The ESD amends the following two Records of Decision (ROD)s: Massachusetts Military Reservation, 
Record of Decision Area of Contamination CS-16/CS-17 Source Areas, Final, May 1999 (CS-16/CS-17 
ROD); and Massachusetts Military Reservation, Record of Decision Area of Contamination FTA-2/LF-2, 
PFSA/FS-10/FS-ll, SD-2/FS-6/FS-8, SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5 Source Areas, Final September 
1998 (6 AOC ROD). These two RODs were amended by one of the following two previous ESDs: 
Explanation of Significant Differences to the Final Record of Decision, Areas of Contamination FTA-2/LF- 
2, PFSA/FS-10/FS-22, SD-2/FS-6/FS-8, SD-3/FTA-3/CY-4, SD4, and SD-5/FS-5 Source Areas, Final, October 
2000 (the 2000 ESD); and Explanation of Significant Differences Areas of Contamination, CS-10 (A, 8 & E), 
CS16/CS I7, FS-9, SD-2/FS-6/FS-8, and SD-3/FTA-3/CY-4, Final, January 2003 (the 2003 ESD). 

AOC CS-16/CS-17 is an 80 acre site located at the JBCC waste water treatment facility along the southern 
boundary of the Cantonment Area and is located within the town of Sandwich, near the intersection of 
the Falmouth-Mashpee town lines. The Remedial Investigation was completed in 1991. Chlorinated 
solvents, polychlorinated biphenyls (PCBs), pesticides, and heavy metals were found in the active and 
inactive sludge drying beds and the former sewage sludge disposal area above risk based 
concentrations. The selected remedy for CS-16/CS-17 included excavation, onsite cold-mix asphalt 



This information is available in alternate format. Call Michelle Waters -Ekanem, Diversity Director, at 617-292.5751. TDD# 1 -866-539-7622 or 1-617-574-6668 

MassDEP Website: www.mass.gov/dep 

Printed or Recycled Paper 



Release Tracking Number 4-0000037 Page 2 of 3 

batching of recyclable contaminated soil, and offsite disposal of non-recyclable contaminated soil. The 
remedial action was completed in 2002 and Remedial Action Report (RAR) was finalized in April 2003. 

The 2003 ESD made three changes to the selected remedy presented in the CS-16/CS-17 ROD: 

• Establishment of Remedial Action Levels for certain inorganic chemicals and petroleum 
hydrocarbons to replace cleanup levels in the ROD; 

• Removal of the asphalt-batching component from the selected remedy; and 

• Expansion of off-site disposal options to include RCRA Subtitle D facilities. 

This ESD proposes to change the dieldrin Remedial Action Level (RAL) from 0.035 mg/kg to 0.050 mg/kg 
and add mono-methyl mercury and total mercury as Contaminants of Concern (COCs) for CS-16/CS-17. 

AOC SD-3/FTA-3/CY-4 is located near the southeastern border of the JBCC on the eastern side of the 
runways, covering approximately 30 acres. The Remedial Investigation was completed in 1993. The 
selected remedy is confirmatory soil sampling with a contingency for excavation and asphalt batching. 
The Remedial Action Report (RAR) was finalized in August 2004, 

The 2003 ESD made the following changes to the selected remedy for AOC SD-3/FTA-3/CY-4 presented 
in the 6 AOC ROD; 

• Establishment of new ecological risk-based cleanup-levels for inorganic chemicals and PCBs; 

• Removal of the asphalt-batching component from the selected remedy; and 

• Expansion of offsite disposal options to include RCRA Subtitle D facilities. 

This ESD adds chrysene and phenanthrene as COCs for AOC SD-3/FTA-3/CY-4. 

AOC SD-4 is a wooded drainage basin located in the southeastern section of JBCC. The Remedial 
Investigation was completed in 1996. The selected remedy was excavation and asphalt batching. This 
ESD changes the petroleum hydrocarbons RAL for AOC SD-4, The MCP Method 1 S-l/GW-1 standards 
for total petroleum hydrocarbon and aliphatic and aromatic hydrocarbons are used as the new RALs. 

AOC SD-5/F5-5 is located in the central part of the JBCC Cantonment Area. The Remedial Investigation 
was completed in 1993. Primary COCs in soil were chlorinated solvents, petroleum hydrocarbons, and 
metals. The selected remedy is excavation, onsite cold-mix asphalt batching of recyclable contaminated 
soils, and offsite disposal of non-recyciable contaminated soils at a facility permitted to treat and/or 
dispose of RCRA hazardous waste. The SD-5/FS-5 RAR was completed in September 2005. The 2000 
ESD modifies the 6 AOC ROD by removing a drainage swaie from the CS-2 Study Area and adds it to AOC 
SD-5. 

This ESD makes the following changes to the selected remedy for AOC SD-5 presented in the ROD; 

• Establishment of new ecological risk-based RALs for chromium, copper, lead, mercury, and zinc; 

• Establishment of ecological and residential risk based cleanup levels for contaminants (vanadium, 
dieldrin, chrysene, fluoranthene, pyrene, and phenanthrene) not considered COCs in the 6 AOC 
ROD; 

• Establishment of current residential cleanup standards (MCP S-l/GW-1 Standards} for total 
petroleum hydrocarbon and aliphatic and aromatic hydrocarbons; 

• Removal of onsite cold-mix asphalt batching component from the selected remedy; 

• Implementation of a soil vapor extraction (SVE) system to treat trichloroethylene (TCE) and 



Release Tracking Number 4-0000037 



Page 3 of 3 



tetrachloroethylene {PCE) in subsurface soil at SD-5 Detail A; and 
• Expansion of offsite disposal options to include RCRA Subtitle D facilities. 

MassDEP concurs with the ESD. The remedies ensure a sufficient and protective level of control such 
that none of the contamination will present a significant risk of harm to health, safety, public welfare or the 
environment during any foreseeable period of time. 

MassDEP's concurrence with the ESD is based upon representations made to MassDEP by AFCEC and 
assumes that all information provided is substantially complete and accurate. Without limitation, if 
MassDEP determines that any material omissions or misstatements exist, if new information becomes 
available, if Land Use Controls (LUCs) are not properly implemented, monitored and/or maintained or if 
conditions within any of the AOCs change, resulting in potential or actual human exposure or threats to the 
environment, MassDEP reserves its authority under M.G.L c. 21E, CERCLA, the MCP, the NCP and any other 
applicable law or regulation to require further response actions at IRP AOCs CS-16/CS-17, SD-3/FTA-3/CY- 
4, SD-4, and SD-S/FS-5 including, without limitation, additional investigation, remedial measures, and the 
implementation of LUCs. MassDEP will review relevant information as it becomes available to determine 
if additional investigative and/or remedial measures are necessary for the protection of public health, 
safety, welfare or the environment at IRP AOCs CS-16/CS-17, SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5. 
This includes, without limitation, new regulatory requirements or changes in the environmental 
conditions at IRP AOCs CS-16/CS-17, SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5. 

Please incorporate this letter into the Administrative Record for IRP AOCs CS-16/CS-17, SD-3/FTA- 
3/CY-4, SD-4, and SD-5/FS-5. if you have any questions regarding this matter, please contact Leonard J. 
Pinaud, Chief, State & Federal Site Management Section, at (508) 946-2871 or Millie Garcia-Serrano, 
Deputy Regional Director of the Bureau of Waste Site Cleanup at (508} 946-2727. 



4-0000037 Multi-AOC Source ESD Concurrence Letter 09-2013 

ec: Philip Weinberg, Regional Director 

Millie Garcia-Serrano, Deputy Regional Director 

Leonard J. Pinaud, Chief, State & Federal Site Management 

Dawn Stolfi Stalenhoef, Regional Counsel 

Mark Begley, Environmental Management Commission 

MassDEP Southeast Region 

MMR Senior Management Board 

MMR Plume Cleanup Team 

Upper Cape Boards of Selectmen 

Upper Cape Boards of Health 




Sincerely. 



Benjamin J. Ericson 
Assistant Commissioner 
Bureau of Waste Site Cleanup 



LAP/